SEC Petition Evaluation Report
 

Petition SEC-00108 

Report Rev #: 0 Report Submittal Date: _3/14/2008 

Subject Expert(s): Joseph S. Guido 

Site Expert(s): N/A 

Petition Administrative Summary 

Petition Under Evaluation 

Petition # Petition 

Type 

Petition A 

Receipt Date 

DOE/AWE Facility Name 

SEC-00108 83.14 3/12/2008 Nuclear Materials and Equipment Corporation (NUMEC) 

Parks Township 

Proposed Class Definition 

All Atomic Weapons Employer employees who worked at the Nuclear Materials and Equipment Corporation plant in 

Parks Township, Pennsylvania, from June 1, 1960 through December 31, 1980, for a number of work days aggregating at 

least 250 work days, occurring either solely under this employment or in combination with work days within the 

parameters established for one or more other classes of employees in the SEC. 

Related Petition Summary Information 

SEC Petition Tracking #(s) Petition Type DOE/AWE Facility Name Petition Status 

None 

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name 

None 

ORAU Lead Technical Evaluator: Joseph S. Guido ORAU Review Completed By: Michael S. Kubiak 

Peer Review Completed By: [Signature on file] 

T. D. Taulbee

03/14/2008 

Date 

SEC Petition Evaluation Reviewed By: [Signature on file] 

J. W. Neton 

03/14/2008 

Date 

SEC Evaluation Approved By: [Signature on file] 

Larry Elliott 

03/14/2008 

Date 
SEC-00108 03-14-08 FINAL NUMEC Parks Township 

This page intentionally left blank 

2 of 21 
 

SEC-00108 03-14-08 FINAL NUMEC Parks Township 

Evaluation Report Summary: SEC-00108, NUMEC Parks Township 

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH) 

addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) as defined 

by the Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 

U.S.C. § 7384 et seq. (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of 

Employees as Members of the Special Exposure Cohort under the Energy Employees Occupational 

Illness Compensation Program Act of 2000. 

NIOSH-Proposed Class Definition 

The NIOSH-proposed class includes all Atomic Weapons Employer (AWE) employees who worked 

at the Nuclear Materials and Equipment Corp. plant in Parks Township, Pennsylvania from June 1, 

1960 through December 31, 1980 for a number of work days aggregating at least 250 work days, 

occurring either solely under this employment or in combination with work days within the 

parameters established for one or more other classes of employees in the SEC. 

Feasibility of Dose Reconstruction 

Per EEOICPA and 42 C.F.R. § 83.14(b), NIOSH has established that it does not have sufficient 

information to complete dose reconstructions for individual members of the class with sufficient 

accuracy. NIOSH lacks adequate and reliable personal monitoring data, workplace monitoring data, 

and source term descriptions, making reconstruction of internal doses infeasible. 

Health Endangerment Determination 

The NIOSH evaluation did not identify evidence supplied by the petitioners or from other sources that 

would establish that the class was exposed to radiation during a discrete incident likely to have 

involved exceptionally high-level exposures, such as nuclear criticality incidents or other events 

involving similarly high levels of exposures. However, the evidence reviewed in this evaluation 

indicates that some workers in the class may have accumulated chronic radiation exposures through 

intakes of radionuclides and direct exposure to radioactive materials. Consequently, in accordance 

with 42 C.F.R. § 83.13(c)(3)(ii), NIOSH has determined that health may have been endangered for 

those workers covered by this evaluation who were employed for a number of work days aggregating 

at least 250 work days within the parameters established for this class, or in combination with work 

days within the parameters established for one or more other classes of employees in the SEC. 

3 of 21 
SEC-00108 03-14-08 FINAL NUMEC Parks Township 

This page intentionally left blank 

4 of 21 
SEC-00108 03-14-08 FINAL NUMEC Parks Township 

Table of Contents 

Evaluation Report Summary: SEC-00108, NUMEC Parks Township ................................................... 3 

1.0 Purpose and Scope.......................................................................................................................... 7 

2.0 Introduction .................................................................................................................................... 7 

3.0 NIOSH-Proposed Class Definition and Petition Basis................................................................... 8 

4.0 Radiological Operations Relevant to the Proposed Class .............................................................. 8 

4.1 Operations Description .......................................................................................................... 8 

4.2 Radiation Exposure Potential from Operations ................................................................... 11 

4.3 Time Period Associated with Radiological Operations....................................................... 11 

4.4 Site Locations Associated with Radiological Operations ................................................... 11 

4.5 Job Descriptions Affected by Radiological Operations ...................................................... 12 

5.0 Summary of Available Monitoring Data for the Proposed Class ................................................. 12 

5.1 Internal Personnel Monitoring Data .................................................................................... 12 

5.2 External Personnel Monitoring Data ................................................................................... 13 

5.3 Workplace Monitoring Data................................................................................................ 13
 

5.4 Radiological Source Term Data .......................................................................................... 13 

6.0 Feasibility of Dose Reconstruction for the Proposed Class ......................................................... 14 

6.1 Feasibility of Estimating Internal Exposures ...................................................................... 14 

6.2 Feasibility of Estimating External Exposures ..................................................................... 16 

7.0 Summary of Feasibility Findings for Petition SEC-00108........................................................... 17 

8.0 Evaluation of Health Endangerment for Petition SEC-00108...................................................... 17 

9.0 NIOSH-Proposed Class for Petition SEC-00108 ......................................................................... 18 

10.0 Evaluation of Second Similar Class ............................................................................................. 18 

11.0 References .................................................................................................................................... 20 

5 of 21 
SEC-00108 03-14-08 FINAL NUMEC Parks Township 

This page intentionally left blank 

6 of 21 
 

 

SEC-00108 03-14-08 FINAL NUMEC Parks Township 

SEC Petition Evaluation Report for SEC-00108 

1.0 Purpose and Scope 

ATTRIBUTION AND ANNOTATION: This is a single-author document. All conclusions drawn from 

the data presented in this evaluation were made by the Oak Ridge Associated Universities Team Lead 

Technical Evaluator: Joseph S. Guido, MJW Corporation, Inc. These conclusions were peerreviewed by the individuals listed on the cover page. The rationales for all conclusions in this 

document are explained in the associated text. 

This report evaluates the feasibility of reconstructing doses for all employees who worked at a specific 

facility during a specified time. It provides information and analysis germane to considering a petition 

for adding a class of employees to the Congressionally-created Special Exposure Cohort (SEC). 

This report does not make any determinations concerning the feasibility of dose reconstruction that 

necessarily apply to any individual energy employee who might require a dose reconstruction from 

NIOSH, with the exception of the employee whose dose reconstruction could not be completed, and 

whose claim consequently led to this petition evaluation. The finding in this report is not the final 

determination as to whether or not the proposed class will be added to the SEC. This report will be 

considered by the Advisory Board on Radiation and Worker Health (the Board) and by the Secretary 

of Health and Human Services (HHS). The Secretary of HHS will make final decisions concerning 

whether or not to add one or more classes to the SEC in response to the petition addressed by this 

report. 

This evaluation, in which NIOSH provides its findings on both on the feasibility of estimating 

radiation doses of members of this class with sufficient accuracy and on health endangerment, was 

conducted in accordance with the requirements of EEOICPA and 42 C.F.R. § 83.14. 

2.0 Introduction 

Both EEOICPA and 42 C.F.R. pt. 83 require NIOSH to evaluate qualified petitions requesting the 

Department of Health and Human Services add a class of employees to the SEC. The evaluation is 

intended to provide a fair, science-based determination of whether it is feasible to estimate, with 

sufficient accuracy, the radiation doses of the proposed class of employees through NIOSH dose 

reconstructions.1 

NIOSH is required to document its evaluation in a report, and to do so, relies upon both its own dose 

reconstruction expertise as well as technical support from its contractor, Oak Ridge Associated 

Universities (ORAU). Once completed, NIOSH provides the report to both the petitioners and the 

Advisory Board on Radiation and Worker Health. The Board will consider the NIOSH evaluation 

report, together with the petition, comments of the petitioner(s) and such other information as the 

Board considers appropriate, to make recommendations to the Secretary of HHS on whether or not to 

1

 NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and 

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas. 

7 of 21 
 

 

 

 

SEC-00108 03-14-08 FINAL NUMEC Parks Township 

add one or more classes of employees to the SEC. Once NIOSH has received and considered the 

advice of the Board, the Director of NIOSH will propose a decision on behalf of HHS. The Secretary 

of HHS will make the final decision, taking into account the NIOSH evaluation, the advice of the 

Board, and the proposed decision issued by NIOSH. As part of this final decision process, the 

petitioner(s) may seek a review of certain types of final decisions issued by the Secretary of HHS.2 

3.0 NIOSH-Proposed Class Definition and Petition Basis 

The NIOSH-proposed class includes all AWE employees who worked at the Nuclear Materials and 

Equipment Corp. (NUMEC) plant in Parks Township, Pennsylvania from June 1, 1960 through 

December 31, 1980 for a number of work days aggregating at least 250 work days, occurring either 

solely under this employment or in combination with work days within the parameters established for 

one or more other classes of employees in the SEC. During this period, employees at this facility 

were involved in nuclear research and production of nuclear materials involving isotopes of uranium, 

plutonium, thorium, polonium, radium, iridium, cobalt, mixed fission products and activation 

products. 

The evaluation responds to the Petition designated SEC-00108 which was submitted by an EEOICPA 

claimant whose dose reconstruction could not be completed by NIOSH due to a lack of sufficient 

dosimetry-related information. This claimant was employed from 1973 – 1977. NIOSH’s 

determination that it is unable to complete a dose reconstruction for an EEOICPA claimant is a 

qualified basis for submitting an SEC petition pursuant to 42 C.F.R. § 83.9(b). 

4.0 Radiological Operations Relevant to the Proposed Class 

The following subsections summarize the radiological operations at the NUMEC Parks Township site 

from June 1, 1960 to December 31, 1980 and the information available to NIOSH to characterize 

particular processes and radioactive source materials. Using available sources, NIOSH has attempted 

to gather process and source descriptions, information regarding the identity and quantities of 

radionuclides of concern, and information describing processes through which the radiation exposures 

of concern may have occurred and the physical environment in which they may have occurred. The 

information included within this evaluation report is meant only to be a summary of the available 

information. 

4.1 Operations Description 

Construction on the NUMEC Parks Township site began on September 28, 1959 and was completed 

by May 1960. Receipt of radioactive materials (plutonium) began in June 1960; however, the Atomic 

Energy Commission (AEC) license for operation was not approved until March 1961. The following 

process descriptions are based on: Description of Processes at Parks Township Facility (BWXT/date 

unknown); Brief History of NUMEC to Present B&W PANSO (Former Production Manager, 2007). 

2007); and Large Scale Processing of Plutonium in an Industrial Plutonium Plant (Caldwell, 1970). 

2 See 42 C.F.R. pt. 83 for a full description of the procedures summarized here. Additional internal procedures are 

available at http://www.cdc.gov/niosh/ocas. 

8 of 21 
SEC-00108 03-14-08 FINAL NUMEC Parks Township 

Building A: Plutonium Processing 

Building A was constructed in five major phases from 1959 until 1970. The original portion of the 

building was designed as a plutonium laboratory to perform research and development (R&D) leading 

to plutonium-based products for emerging nuclear businesses. Initial operations in Building A were 

authorized by the AEC in 1960. Many experimental fuel forms and compositions were produced there 

in the 1960s, including oxides, carbides, and metal alloys. Work with nuclear materials in Building A 

was conducted in fabrication areas designated as Fab 1 through 7 and Fab 9, and in several small 

laboratories adjacent to the Fab areas. Indications are that all significant work on nuclear fuel 

materials was done within containment systems such as radiochemical hoods and glove boxes. 

Plutonium scrap recovery was an integral part of Building A operations. Scrap recovery operations 

were conducted in Fab 5 until August 1, 1967. Recovery operations were moved in 1968 to a much 

larger, improved operation in Fab 6 that operated throughout the 1970s and into 1980. Conversion of 

plutonium nitrate to plutonium oxide was performed at the north end of Fab 1 inside HEPA-filtered 

glove boxes. 

The chemical, physical, mechanical, and radiochemical properties of in-process fuel, finished fuel 

forms, and radiation sources were determined on small samples in several small laboratory rooms 

adjacent to the west side of Fabs 1, 2, 3, and 4. Separate laboratories existed for wet chemistry, 

metallography and mechanical properties, and radiochemistry. An analytical chemistry laboratory 

was also installed in Fab 5 after removal of the scrap recovery process equipment; however, this lab 

only operated for about six months during 1979-80. 

Alpha, neutron, and thermal sources were also produced in Building A. The two most common 

neutron sources were double-encapsulated plutonium-beryllium metallic sources and compacted 

mixtures of americium oxide and beryllium metal powders. These neutron sources were made in the 

Fab 4 area. A standard alpha source was made that consisted of a plutonium oxide film deposited on 

one or both sides of a flat metal backing plate. Limited quantities of various other neutron, beta, and 

gamma sources were also made to specific customer specifications. Materials used in these specialty 

sources included polonium, plutonium, americium, iridium, cesium, cobalt, and beryllium. Source 

manufacturing always took place inside HEPA-filtered glove boxes, except for high-activity sources 

fabricated in the Building A Hot Cell. 

Gamma sources of Ir-192 and Co-60, which required extensive shielding (i.e., a hot cell), and 

high-yield neutron sources of Po-210/beryllium were fabricated in the Building A Hot Cell, but the 

primary work performed in the Hot Cell was destructive post-irradiation examination of test capsules 

and fuel pins irradiated in research reactors. 

All plutonium glove boxes and fume hoods were removed from Building A during a 1981-1983 

deactivation program. Most of the effluent streams that existed during the years of plutonium fuel 

production were thus eliminated. The workload in Building A then shifted to repair and 

refurbishment of contaminated equipment used at reactor sites, building decontamination, and Low 

Level Radioactive Waste volume reduction services for commercial customers. As commercial work 

slowed in the mid-1990s, the pace of building decontamination increased. 

9 of 21 
SEC-00108 03-14-08 FINAL NUMEC Parks Township 

Building B: Multiple-Purpose Facilities 

Building B was constructed in three stages, beginning in 1961 when the Hafnium Facility was built. 

The second stage occurred in 1963 when the Metals Plant was built to the east of the Hafnium 

Facility. The third stage occurred in 1964, when the space between the Hafnium Facility and the 

Metals Plant was enclosed to create the Machine Shop. Later in its history, the combined facility 

became known as the Metals Building, and then Building B. 

Depleted uranium was the primary radioactive material processed in Building B, although smaller 

quantities of natural uranium, thorium, and Pu-238 were also processed. The depleted uranium was 

primarily in the form of metal or metal alloy. Processing consisted mostly of forming, rolling, and 

machining operations that do not generate significant airborne emissions. The thorium work 

consisted of thorium fuel encapsulation and production of thorium containing experimental fuel. 

Hafnium Facility 

While most of the Hafnium Facility was used to produce bars of zirconium and hafnium, Pu-238 

nitrate was converted into an oxide product in a room in the northwest corner of the Hafnium Facility 

known as the Plutonium Annex, under an AEC contract. The conversion process for the Pu-238 

nitrate was very similar to the process used for converting Pu-239 nitrate into fuel products in 

Building A except that only oxalate precipitation was used. The conversion was performed in eight 

HEPA-filtered glove boxes. 

Machine Shop 

The Machine Shop, which connected the Hafnium Facility to the Metals Plant, was used to fabricate 

equipment and machine metals in support of the production lines at the NUMEC Apollo and NUMEC 

Parks Township sites. The equipment in the Machine Shop included drill presses, lathes, shears, 

grinders, polishers, welders, sandblasting, degreasing and other associated metal-working machinery. 

Machining of depleted uranium was performed in the Machine Shop, as was repair/refurbishment of 

equipment from the Apollo and Parks facilities. Some of this equipment contained levels of 

radioactivity that exceeded the then-existing criteria for release for unrestricted use. 

All machining operations took place on the ground floor. The second floor contained primarily 

offices and a training room, although a small environmental laboratory was in use at the south end of 

the second floor until 1991. After 1991, most of the second floor was used as office space until 

decontamination operations started in Building B in late 1996. 

Metals Plant 

Built in 1963, the original layout of the first floor of the Metals Plant included a variety of equipment 

used in the production of uranium metal alloys. Metals production from the Metals Plant appears to 

have been small-scale and intermittent. During a plant tour by the Atomic Energy Commission 

(AEC), Smith (1965) noted that the Metals Plant was engaged in the production of thorium containing 

experimental elements. Most of the processing equipment was removed for resale or disposal in 

10 of 21 
SEC-00108 03-14-08 FINAL NUMEC Parks Township 

1973-74. During the mid-1970s, a portion of the high bay area was used to machine non-radioactive 

fan components. 

The second floor of the Metals Plant initially contained only one office, but over the years other 

offices were added along with two physical and mechanical testing laboratories for quality control 

testing, and an Energy Conversion Lab (also called the R&D Lab) where R&D projects were 

performed, such as the development of Pu-238-fueled heart pacemakers, under an AEC sealed-source 

license. 

Building C: High-Enriched Uranium Processing 

Combined with the general expansion of Building A in the 1969-70 time period, a new building was 

erected to the east of Building A. The building sat unused until 1973 when the company received a 

contract to fabricate a high-enriched uranium product, as authorized by the AEC in Amendment No. 

83 to SNM-414. 

4.2 Radiation Exposure Potential from Operations 

Based on the site operations outlined in Section 4.1 and NIOSH evaluations of available dosimetry 

data, NIOSH concluded that workers at NUMEC Parks Township had the potential for internal 

radiation exposures (from uranium, thorium, plutonium, polonium, iridium-192, cobalt-60, and mixed 

fission and activation products) and external exposures (from beta-gamma and neutron radiation) 

during the performance of their work. 

4.3 Time Period Associated with Radiological Operations 

Per the DOE Office of Health, Safety and Security, the time period associated with EEOICPAcovered AWE operations at the NUMEC Parks Township site is from 1957 through 1980 (DOE, 

2008). As presented in Section 4.1, NIOSH has determined that receipt of radioactive materials 

(plutonium) at the NUMEC Parks Township site began in June 1960 (Caldwell, 1970). NIOSH has 

been unable to determine a more specific date for when AWE radiological operations began; 

therefore, this evaluation assumes that AWE radiological operations began on June 1, 1960. NIOSH 

has also been unable to establish a definitive date in 1980 when AWE radiological operations ceased; 

therefore, this evaluation assumes that the AWE radiological operations at the NUMEC Parks 

Township site ceased on December 31, 1980. 

4.4 Site Locations Associated with Radiological Operations 

NIOSH does not have not access to information that either details or restricts the use of AEC-related 

radionuclides to particular areas of the NUMEC Parks Township site. Without such information, 

NIOSH is unable to limit the SEC class based on work locations within the site. Consequently, the 

entire NUMEC Parks Township site is included in the proposed SEC class. 

11 of 21 
SEC-00108 03-14-08 FINAL NUMEC Parks Township 

4.5 Job Descriptions Affected by Radiological Operations 

According the NUMEC Health and Safety Manual (NUMEC, 1974), all personnel who normally 

worked in the Restricted Areas at the Parks Township Site were required to wear dosimeters, thus 

indicating external monitoring may be adequate to define the class. However, during an AEC 

inspection in 1967 (USAEC, 1967), the inspectors noted that the radiation dose rate in an unrestricted 

area exceeded 2 mrem/hr, thus exceeding regulatory requirements for unrestricted areas. Surveys of 

unrestricted areas (NUMEC, 1968) were conducted between 1966 to 1968 also indicate periodic dose 

rates approximately 12 mR/hr in unrestricted areas outside the scrap recovery facility (FAB-5). 

Although most of the dose rates were relatively low (background levels to < 0.5 mR/hr) around the 

facility, these periodic higher dose rates in unrestricted areas indicate that at various times 

unmonitored workers could have been exposed to low to moderate doses of radiation. In addition, 

NIOSH has limited documentation that associates job titles and/or job assignments with specific 

radiological operations from which to develop a co-worker model for these unmonitored workers. 

Due to the lack of information regarding worker job descriptions, and lack of knowledge concerning 

worker movements on the NUMEC Parks Township site during the AWE period and evidence of 

measurable radiation exposures in unrestricted areas, NIOSH is unable to use job descriptions to 

define or limit the proposed SEC class. 

5.0 Summary of Available Monitoring Data for the Proposed Class 

The primary data used for determining internal exposures are derived from personal monitoring data, 

such as urinalyses, fecal samples, and whole-body counting results. If these are unavailable, the air 

monitoring data from breathing zone and general area monitoring are used to estimate the potential 

internal exposure. If personal monitoring and breathing zone area monitoring are unavailable, internal 

exposures can sometimes be estimated using more general area monitoring, process information, and 

information characterizing and quantifying the source term. 

This same hierarchy is used for determining the external exposures to the cancer site. Personal 

monitoring data from film badges or thermoluminescent dosimeters (TLDs) are the primary data used 

to determine such external exposures. If there are no personal monitoring data, then exposure rate 

surveys, process knowledge, and source term modeling can sometimes be used to reconstruct potential 

exposure. 

A more detailed discussion of the information required for dose reconstruction can be found in 

OCAS-IG-001, External Dose Reconstruction Implementation Guideline, and OCAS-IG-002, Internal 

Dose Reconstruction Implementation Guideline. These documents are available at: 

http://www.cdc.gov/niosh/ocas/ocasdose.html. 

NIOSH data capture efforts included making formal requests to the former site operator Babcock and 

Wilcox (BWXT) and the NRC. Personal monitoring data are available for monitored individuals who 

worked at NUMEC Parks Township from 1960 to the end of the decommissioning phase. 

5.1 Internal Personnel Monitoring Data 

12 of 21 
SEC-00108 03-14-08 FINAL NUMEC Parks Township 

Urine bioassay data for americium, plutonium, and uranium are available for workers at NUMEC 

Parks Township from 1961 through 1976. Fecal bioassay results for americium, plutonium and 

uranium are available from 1969-76. A very limited number of bioassay samples are available for 

thorium (six urine and five fecal samples, all collected in June 1971) and mixed fission products (four 

urine samples collected in September 1962; two urine samples collected in June 1971). The thorium 

bioassay samples also appear to have been for employees who worked predominately at the Apollo 

plant. 

The contractor Controls for Environmental Pollution (CEP) was used by NUMEC to analyze urine 

and fecal bioassay samples from 1976-93. Available information indicates that CEP was the sole such 

contractor used during this period. In 1994, CEP came under suspicion of data falsification for 

analyses performed for Sandia National Laboratories (Sandia) from 1992-94. The allegations were 

serious enough that federal authorities executed a search warrant for CEP records, and the NRC and 

DOE issued press releases to their licensees that the accuracy of the data provided by CEP was 

questionable (NRC 1994). Although the NUMEC period almost completely predates these events, 

there is no indication for what time period the CEP data can be considered reliable. Because it is not 

clear to NIOSH what actions may have been taken by NUMEC in response to these allegations, 

NIOSH is unable to validate NUMEC monitoring data for the period containing CEP results. A 1994 

press release by the NRC to its licensees states that the events related to CEP give reason to question 

the sample results received from the company (NRC, 1994). 

NUMEC Parks Township personnel were also evaluated by whole-body counting from 1968-85. 

NUMEC initially used the services from the Helgeson mobile body counter and later had a contract 

with the University of Pittsburgh. Only employees who normally worked in the restricted area were 

monitored for U-235 and/or Pu-239/Am-241. 

5.2 External Personnel Monitoring Data 

External dosimetry data for NUMEC Parks Township employees who normally worked in the 

restricted areas are available from 1961-83. 

5.3 Workplace Monitoring Data 

Air sampling data sheets (for both uranium and plutonium) are available starting in 1961 in the form 

of general air samples and breathing zone samples. Available data range in frequency from numerous 

samples per year (greater than 100) to sporadic sample coverage. At this time NIOSH has not been 

able to determine whether the difference in sample frequency represents a variation in the degree of 

radiological risk, changes in monitoring programs, or lapses in captured data. 

5.4 Radiological Source Term Data 

Radioactive materials handled at the NUMEC Parks Township site included isotopes of plutonium, 

uranium, americium, thorium, polonium, iridium, and mixed fission and activation products. Without 

additional documentation, NIOSH cannot make assumptions about particular radionuclides, 

quantities, or forms of source materials that may have been used in specific areas of the site. 

13 of 21 
SEC-00108 03-14-08 FINAL NUMEC Parks Township 

6.0 Feasibility of Dose Reconstruction for the Proposed Class 

42 C.F.R. § 83.14(b) states that HHS will consider a NIOSH determination that there was insufficient 

information to complete a dose reconstruction, as indicated in this present case, to be sufficient, 

without further consideration, to conclude that it is not feasible to estimate the levels of radiation 

doses of individual members of the class with sufficient accuracy. 

In the case of a petition submitted to NIOSH under 42 C.F.R. § 83.9(b), NIOSH has already 

determined that a dose reconstruction cannot be completed for an employee at the DOE or AWE 

facility. This determination by NIOSH provides the basis for the petition by the affected claimant. 

Per § 83.14(a), the NIOSH-proposed class defines those employees who, based on completed 

research, are similarly affected and for whom, as a class, dose reconstruction is similarly not feasible. 

In accordance with § 83.14(a), NIOSH may establish a second class of coworkers at the facility for 

whom NIOSH believes that dose reconstruction is similarly infeasible, but for whom additional 

research and analysis are required. If so identified, NIOSH would address this second class in a 

separate SEC evaluation rather than delay consideration of the claim currently under evaluation (see 

Section 10.0). This would allow NIOSH, the Board, and HHS to complete, without delay, their 

consideration of the class that includes a claimant for whom NIOSH has already determined a dose 

reconstruction cannot be completed, and whose only possible remedy under EEOICPA is the addition 

of a class of employees to the SEC. 

This section of the report summarizes research findings by which NIOSH determined that it lacked 

sufficient information to complete the relevant dose reconstruction and on which basis it has defined 

the class of employees for which dose reconstruction is not feasible. NIOSH’s determination relies on 

the same statutory and regulatory criteria that govern consideration of all SEC petitions. 

6.1 Feasibility of Estimating Internal Exposures 

Based on its review of available data, NIOSH has concluded that information pertaining to internal 

dosimetry is inadequate to ensure sufficiently accurate reconstruction of internal exposures for the 

NUMEC Parks Township operations. Specific inadequacies include: 

•	 Inadequate Description and Monitoring of Thorium Operations: A very small number of thorium 

bioassay measurements is available for 1971 (see Section 5), and these appear to be for the Apollo 

plant. During the data capture phase, NIOSH identified a limited amount of air sampling data for 

thorium. However, it appears all of the air samples are from the NUMEC Apollo plant in 1970 

and 1971. The full scope of thorium operations at the Parks Township site is not known. 

Documents related to NUMEC operations indicate that thorium operations at Parks Township 

included fuel encapsulation in 1963 (Former Production Manager, 1963) and production of 

thorium containing experimental elements in 1965 (Smith, 1965). In addition documentation from 

the Bureau of Mines (Parker, 1969; Woodmansee, 1970) lists the Parks Township site as a 

“thorium fabrication facility.” Similarly, a 1970 Fernald report (Woodmansee, 1971) lists the 

Parks Township site as a thorium “nuclear fuel producer.” 

To date, NIOSH has been unable to find detailed process descriptions or information concerning 

the overall scope of the thorium work, such as when actual operations stopped, whether the 

14 of 21 
 

SEC-00108 03-14-08 FINAL NUMEC Parks Township 

operations areas were decontaminated and decommissioned, and whether all thorium was removed 

from the site. NIOSH has determined that due to the limited information on the operational 

period, the small amount of personnel monitoring data, and the lack of detailed information 

describing the work processes, NIOSH is unable to establish sufficiently accurate bounding 

conditions for potential exposures associated with thorium work at the NUMEC Parks Township 

site. 

•	 Questionable Bioassay Data from CEP: Controls for Environmental Pollution (CEP) came under 

suspicion of data falsification in 1994 after bioassay data provided to Sandia were found to be 

questionable. In November 1994, both DOE and the NRC advised contractors and/or licensees to 

seriously question the accuracy of any analytical results provided by CEP (NRC, 1994). 

The seriousness of the Sandia events calls into question the reliability of CEP’s analytical services 

for other nuclear facilities, including those it provided to NUMEC Parks Township from 1976-93. 

NIOSH is not aware of any documentation that would limit the time period during which CEP’s 

analytical processes were considered to be flawed, or that shows why only the early 1990s data 

provided to Sandia should be considered suspect. Based on available documentation, NIOSH 

concluded that it must consider all CEP data provided to NUMEC Parks Township to be suspect, 

and therefore, cannot use these data to support dose reconstructions, SEC evaluations, or the 

development of co-worker models. Since CEP was the major bioassay contractor for NUMEC 

from 1976-93, this creates a gap in the usable monitoring data available for dose reconstruction. 

As mentioned in section 5.3 air sampling for plutonium and uranium started in 1961 and whole 

body counts are available for workers starting in 1968. The air sampling data and whole body 

count results could be used to develop a co-worker model. However, it does not appear everyone 

with the potential for exposure received a whole body count nor is it clear the protocol used for 

whole body counting. Based on the infeasibility to reconstruct doses associated with thorium and 

radionuclides associated with source production (e.g., polonium and iridium) NIOSH did not 

pursue a detailed analysis to determine if there are a sufficient number of data points to support a 

co-worker model. 

•	 Lack of Information on Fabrication of Radiation Sources and Work with Irradiated Fuel: 

Historical documentation indicates that NUMEC fabricated neutron sources (e.g., Po-Be and PuBe), Co-60 and Ir-192 sources. In addition, irradiated fuel was handled in the Hot Cell facility. 

Exposures from these activities are evident from incident reports (Puechl, 1965, 1967) and wholebody counting records that indicate uptakes of these radionuclides (Caldwell, 1968). However, to 

date NIOSH has not been able to locate any detailed process descriptions for these operations, any 

source term data, any personnel or area monitoring data specifically associated with these 

processes, nor any records establishing the exact time period these operations took place. 

Therefore, NIOSH concluded that it has insufficient data to establish sufficiently accurate 

bounding conditions for doses resulting from these operations. 

Workers at NUMEC Parks Township had the potential for radiological internal exposures from 

radioactive materials, including uranium, thorium, plutonium, americium, polonium, Ir-192, Co-60, 

and mixed fission and activation products. Given the limited personal monitoring data, workplace 

monitoring data, and source term descriptions for the various radiological operations at NUMEC 

Parks Township, it is not feasible for NIOSH to reconstruct with sufficient accuracy the internal doses 

15 of 21 
 

SEC-00108 03-14-08 FINAL NUMEC Parks Township 

that may have been received from potential exposure to radionuclides during the AWE radiological 

operations at the NUMEC Parks Township site from June 1, 1960 through December 31, 1980. 

Although NIOSH concluded that there are inadequate data to permit sufficiently accurate 

reconstruction of internal doses at NUMEC Parks Township, NIOSH does intend to use any available 

non-CEP internal monitoring data that may reside in an individual’s file (and that can be interpreted 

using existing NIOSH dose reconstruction processes or procedures) to support partial internal dose 

reconstructions for claimants not qualifying for inclusion in the SEC. 

6.2 Feasibility of Estimating External Exposures 

This evaluation responds to a petition based on NIOSH determining that internal radiation exposure 

could not be reconstructed for a dose reconstruction referred to NIOSH by the Department of Labor. 

As noted above, HHS will consider this determination to be sufficient without further consideration to 

determine that it is not feasible to estimate the levels of radiation doses of individual members of the 

class with sufficient accuracy. Consequently, it is not necessary for NIOSH to fully evaluate the 

feasibility of reconstructing external radiation exposure in this case. 

As mentioned in section 5.2, NIOSH has external monitoring data starting in 1961. NIOSH intends to 

use any available external monitoring data that may reside in an individual’s file (and that can be 

interpreted using existing NIOSH dose reconstruction processes or procedures) to support partial 

external dose reconstructions for claimants not qualifying for inclusion in the SEC. 

NIOSH considers adequate reconstruction of medical dose for NUMEC Parks Township workers 

likely to be feasible by using claimant-favorable assumptions as well as the applicable protocols in the 

complex-wide Technical Information Bulletin, Dose Reconstructions from Occupationally Related 

Diagnostic X-Ray Procedures (ORAUT-OTIB-0006). 

16 of 21 
SEC-00108 03-14-08 FINAL NUMEC Parks Township 

7.0 Summary of Feasibility Findings for Petition SEC-00108 

This report evaluated the feasibility for estimating the dose, with sufficient accuracy, for all AWE 

employees at the NUMEC Parks Township site from June 1, 1960 through December 31, 1980. 

NIOSH determined that it lacks sufficient bioassay monitoring data, workplace monitoring data, and 

source term or processing information to reconstruct the internal exposures at the facility during this 

time period. Consequently, NIOSH finds that it is not feasible to estimate with sufficient accuracy the 

radiation doses resulting from internal exposures received by members of this class of employees. 

NIOSH has documented herein that it cannot complete the dose reconstruction related to this petition. 

The basis of this finding is specified in this report, which demonstrates that NIOSH does not have 

access to sufficient information to estimate either the maximum radiation dose incurred by any 

member of the class or to estimate such radiation doses more precisely than a maximum dose 

estimate. 

Members of this class at the NUMEC Parks Township site may have received internal and external 

exposures from various radionuclides at the plant. NIOSH lacks sufficient information, which 

includes personnel and workplace monitoring data and radiological source term information, to allow 

it to estimate the total internal exposure to which the proposed class may have been exposed. 

8.0 Evaluation of Health Endangerment for Petition SEC-00108 

The health endangerment determination for the class of employees covered by this evaluation report is 

governed by EEOICPA and 42 C.F.R. §§ 83.14(c) and 83.13(c)(3). Pursuant to these requirements, if 

it is not feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH 

must determine that there is a reasonable likelihood that such radiation doses may have endangered 

the health of members of the class. The regulations require NIOSH to assume that any duration of 

unprotected exposure may have endangered the health of members of a class when it has been 

established that the class may have been exposed to radiation during a discrete incident likely to have 

involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If 

the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 

required to specify that health was endangered for those workers who were employed for a number of 

work days aggregating at least 250 work days within the parameters established for the class or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

NIOSH has determined that members of the class were not exposed to radiation during a discrete 

incident likely to have involved levels of exposure similarly high to those occurring during nuclear 

criticality incidents. However, the evidence reviewed in this evaluation indicates that some workers in 

the class may have accumulated chronic radiation exposures through intakes of radionuclides and 

from direct exposure to radioactive materials. Consequently, NIOSH is specifying that health was 

endangered for those workers covered by this evaluation who were employed for a number of work 

days aggregating at least 250 work days within the parameters established for this class or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

17 of 21 
 

SEC-00108 03-14-08 FINAL NUMEC Parks Township 

9.0 NIOSH-Proposed Class for Petition SEC-00108 

The evaluation defines a single class of employees for which NIOSH cannot estimate radiation doses 

with sufficient accuracy. This class includes all AWE employees who worked at the Nuclear 

Materials and Equipment Corp. plant in Parks Township, Pennsylvania from June 1, 1960 through 

December 31, 1980 for a number of work days aggregating at least 250 work days, occurring either 

solely under this employment or in combination with work days within the parameters established for 

one or more other classes of employees in the SEC. 

10.0 Evaluation of Second Similar Class 

In accordance with § 83.14(a), NIOSH may establish a second class of coworkers at the facility, 

similar to the class defined in Section 9.0, for whom NIOSH believes that dose reconstruction may not 

be feasible, and for whom additional research and analyses is required. If a second class is identified, 

it would require additional research and analyses. Such a class would be addressed in a separate SEC 

evaluation, so as not to delay consideration of the current claim. At this time, NIOSH has not 

identified a second similar class of employees at the NUMEC plant in Parks Township, Pennsylvania 

for whom dose reconstruction may not be feasible. 

18 of 21 
SEC-00108 03-14-08 FINAL NUMEC Parks Township 

This page intentionally left blank. 

19 of 21 
19392 

SEC-00108 03-14-08 FINAL NUMEC Parks Township 

11.0 References 

42 C.F.R. pt. 81, Guidelines for Determining the Probability of Causation Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal 

Register/Vol. 67, No. 85/Thursday, p. 22296; May 2, 2002; SRDB Ref ID: 19391 

42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID: 

42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special 

Exposure Cohort Under the Energy Employees Occupational Illness Compensation Program Act of 

2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001 

42 U.S.C. §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation 

Program Act of 2000; as amended; OCAS website 

ORAUT-OTIB-0006, Dose Reconstruction from Occupationally Related Diagnostic X-Ray 

Procedures, Rev. 03 PC-1, Oak Ridge Associated Universities, Dec. 21, 2005, SRDB REF ID: 20220 

BWXT/date unknown, Description of Processes at Parks Township Facility; BWXT; date unknown; 

SRDB Ref ID: 16998 

Caldwell, 1968, Whole-Body Counting Data, correspondence to L. D. Low; R. D. Caldwell; May 17, 

1968; SRDB Ref ID: 18151 

Caldwell, 1970, Large-Scale Processing of Plutonium: Radiation Protection Under Commercial 

Conditions, discussion for slide presentation; R. D. Caldwell and T. Potter; date unknown; SRDB Ref 

ID: 22779 

Former Production Manager, 2007 (Name Redacted), Brief History of NUMEC to Present B&W 

Panso; SRDB Ref ID: 31448 

DOE, 2008, DOE Office of Health, Safety and Security EEOICPA web page; 

http://www.hss.energy.gov/healthsafety/fwsp/advocacy/faclist/findfacility.cfm; last accessed on 

March 3, 2008 

NRC, 1994, Accuracy of Bioassay and Environmental Sampling Results; United States Nuclear 

Regulatory Commission; Office of Nuclear Materials Safety and Safeguards; NRC Information Notice 

94-81, November 8, 1994; SRDB Ref ID: 29638 

NUMEC, 1975, NUMEC Parks Township Site Health and Safety Manual – Plutonium Plant; R.A. 

Williams SRDB Ref ID: 28526 

NUMEC, 1968, Unrestricted Area Radiation Surveys from 1966 to 1968; SRDB Ref ID: 19731 

20 of 21 
SEC-00108 03-14-08 FINAL NUMEC Parks Township 

Parker, 1969, Thorium, Preprint from the 1969 Bureau of Mines Minerals Yearbook; J. G. Parker; 

1969; SRDB Ref ID: 29581 

Puechl, 1965, Letter to Eber Price (US AEC), April 15, 1965; K.H. Puechl; SRDB Ref ID: 19742 

Puechl, 1967, Letter to Eber Price (US AEC), March 9,1967; K.H. Puechl; SRDB Ref ID: 19758 

Smith, 1965, Visit to NUMEC’s Plutonium Laboratory and Uranium Facility, January 19, 1965; 

Smith, R. D.; 1965; SRDB Ref ID: 27213 

USAEC, 1967, US AEC Letter to Dr. Zalman Shapiro President of NUMEC, L.D. Low; September 5, 

1967; L.D. Low; SRDB Ref ID: 27213 

Woodmansee, 1970, Thorium, Preprint from the 1970 Bureau of Mines Minerals Yearbook; W. C. 

Woodmansee; Physical Scientist, Division of Nonferrous Metals, U.S. Bureau of Mines; 1970; SRDB 

Ref ID: 29583 

Woodmansee, 1971, Thorium, draft report; W. C. Woodmansee; Geologist, Division of Nonferrous 

Metals, U.S. Bureau of Mines; 1971; SRDB Ref ID: 29561 

21 of 21